State Fire Marshal Interpretations - Care Facilities
Date Issued 04-21-2000 Interpretation 00-003
Topic: Exiting from R, Division 2 Occupancies housing non-ambulatory clients.
Code Section(s): 1007.6.3.2.2, California Building Code (1998)
Requested by: Mary Miller, Fire Marshal, Modesto Fire Department, 1010 Tenth Street, Modesto, CA 95353
1. Can a person exit through two intervening rooms in a Group R, Division 2 Occupancy housing six or less non-ambulatory clients?
One of the two required exits can be through a hallway and then to another bedroom that has an exit directly to the outside. Furthermore, the code also allows the exit to be through an adjacent room (such as a bathroom) and then through a bedroom with direct exit to the outside.
2. Is it the intent of the code to allow both of the required exits to be through intervening rooms?
No. the preferred means of exiting from the bedrooms housing non-ambulatory clients should be directly to the exterior. However, when this is not practical, the exiting may be through an intervening room.
3. Is the hallway considered an intervening room?
The hallway would not be considered an intervening room in this specific case.
4. Can section 1004.2.2 be ignored because section 1007.6.3.2.2 is more specific?
Section 1007.6.3.2.2 is the only section applicable for this issue.
5. Can we apply these requirements to ambulatory facilities?
No. In ambulatory facilities housing six or fewer clients, exiting is required as per a Group R Division 3 Occupancy.
6. Is there a provision for door width for a non-ambulatory client in a wheel chair so they can move freely about a care home?
It appears that everything we find references occupant loads of 10 or more. The code appears to be silent in this regard as it speaks to door widths of rooms housing 10 or more. The intent of the code is to allow the clients to move about freely. Consequently, the doors from the rooms housing non-ambulatory clients must be adequate to accommodate the width of the wheelchair. Since there is no standard size of wheelchair, the door width will have to depend on the particular client housed in the room.
7. Is there a provision for door width for ambulatory clients?
There is not specific code reference for this issue. The requirements would be those that are applicable to a Group R, Division 3 Occupancy.
Date Issued 08-07-00 Interpretation 00-011
Topic: Group R, Division 2 Accessibility
Code Section(s) §13146, Health and Safety Code, Chapter 11, California Building Code (1998 ed.)
Requested by Paul Olkowski, San Mateo City Fire Department, 1941 O’Farrell St. #102, San Mateo, CA 94403-1388
1. Is it the responsibility of the local fire authority to enforce all regulations
for Group R, Division 2 Occupancies, including plan review for new
facilities?
The California Health and Safety Code, Section 13146, requires that the local fire
authority enforce fire and panic regulations in various occupancies. This includes
plan review for compliance with SFM regulations. However, we would encourage
the fire authority to work closely with the local building officials so that a
comprehensive review of all applicable standards is rendered — including locally
adopted ordinances.
2. Is a Group R, Division 2 facility housing non-ambulatory clients required to
comply with the requirements of Chapter 11 concerning Accessibility (e.g.,
fire alarm strobe lights, exterior ramps, 36-inch hallways and doors, leverstyle
door hardware, etc.).
The State Fire Marshal only adopted certain sections of Chapter 11B of the California Building Code in its entirety. Since Chapter 11B is specific to public buildings, those sections adopted by the SFM are not applicable to R-2 Occupancies. Therefore, the accessibility standards applicable to Group R, Division 2 facilities are those adopted at the local level for residential applications as found in Chapters 11 and 11A.
3. When a single-family dwelling applies for a permit to convert the occupancy to a non-ambulatory community care home, is it the intent of the State Building Code to provide the non- ambulatory residents the same accessibility options as for any other occupant?
Please refer to the answer to the prior question as it applies to this question.
Date Issued 11-20-00 Interpretation # 00-017
Topic Fire Drills in Group R, Division 2 Occupancies
Code Section(s) §3.10, Title 19, California Code of Regulations
Requested by: Gregory Lake, Sacramento Metropolitan Fire District, 2101 Hurley Way
Sacramento, CA 95825-3208
Are fire drills required by State regulation in a Group R, Division 2.2.1
Occupancy?
No. There are no requirements for monthly fire drills for a Group R, Division 2
Occupancy. Section 3.10 of Title 19 speaks only to the evacuation and relocation of
occupants. When this code section addresses “fire drills”, it specifically is directed at
those occupancies that do require fire drills (e.g., schools). In addition, State Law
provides that requirements for Group R, Division 2 Occupancies housing six or less
cannot be amended by local ordinance.
Date Issued 11-20-00 Interpretation # 00-019
Topic Accessibility Standards in Group R, Division 2 Occupancies
Code Section(s): Chapters 10 and 11, California Building Code (1998 ed)
Requested by: Gregory Lake, Sacramento Metropolitan Fire District
2101 Hurley Way, Sacramento, CA 95825-3208
In a Group R, Division 3 dwelling, is it the intent of the Code to require the
following before it may house a Group R, Division 2.2.1 Occupancy:
1. Interior “changes in level” ramps with handrails per CBC for access to
common areas not in exit path;
2. 32-inch wide doors to the bathroom, commode room, and other common
use areas not in the exit path from the sleeping areas as noted in Section
1007;
3. Consideration of every common-area door as a required exit door from that
room;
4. Lever hardware on the doors and gates.
No. Common areas are specific to Chapter 11 only and not intended to be inter-changeable with other sections of the Code.
Date Issued 06-17-02 Interpretation 02-014
Topic: Location of Property R-6 Occupancies
Code Section(s) §317A, California Building Code (1998)
Requested by Robert Bohman, Deputy Fire Marshal, Alameda County Fire Department
2241 Redwood Road, Castro Valley, CA 94546
Is it the intent of CBC Section 317A to allow setback from the property line of only three feet for a Group R, Division 6.2 occupancy if the building is designed with a non-rated exterior wall and unprotected openings even when the occupancy load is greater than ten?
No. Section 316A states that a Group R, Division 6.2 occupancy shall not exceed the type of construction as specified for occupancies classified Group R Division 1 occupancy.
Date Issued 06-17-02 Interpretation 02-025
Topic: Changes in Level in Corridors and Hallways R-2 Occupancies
Code Section(s): §1007.6.3.4, California Building Code (1998)
Requested by: Bryan Wadlington, San Miguel Fire Protection District, 2850 Via Orange Way Spring Valley, CA 91978-5331
Since all required exits in Group R, Division 2 occupancies must go to a public way, is it the intent of the State Fire Marshal that Section 1007.6.3.4 of the California Building Code (1998) be used for the entire path of travel to the public way or is this section only intended to apply to the interior hallways and corridors?
Section 1007.6.3.4 applies specifically to the interior exiting system.
Date Issued 12-05-02 Interpretation 02-039
Topic: Changes in Elevations for Group R, Division 2 Occupancies
Code Section(s): Section 1007.6.3.4, California Building Code (1998 ed)
Requested by: Steve Holtrust: Ontario Fire Department, 415 East “B” Street, Ontario, CA 91764
Does Section 1007.6.3.4 apply to all Group R, Division 2 occupancies or only those that have non-ambulatory clients?
No. This section would only apply for non-ambulatory clients as defined in Section 215,
California Building Code.
Date Issued 12-05-02 Interpretation 02-046
Topic: Exiting from Group R-2.2.1 with Non-Ambulatory Clients
Code Section(s): Section 1007.6.3.2.1, California Building Code (1998 ed)
Requested by: Colleen Balch, Carlsbad Fire Department, 1635 Faraday Avenue
Carlsbad, CA 92008
1. Does Section 1007.6.3.2.1 apply to Group R, Division 2.2.1 occupancies that house non-ambulatory clients?
Yes. Section 1007.6.3.2.1 applies to the bedrooms used by non-ambulatory clients in Group R, Division 2.2.1 occupancies built of non-rated construction.
2. How do you apply section 1007.6.3.2.4? It appears that the clients are exiting through more than one intervening room if they exit through the hallway.
For purposes of determining the number of intervening rooms, the room that the clients exit from is not counted and the hallway is not considered a room for purposes of exiting in this type of occupancies. Clients may exit from a bedroom to the hallway and through another bedroom that has a direct exit to the exterior. They may not exit from the hallway into a common living area such as an entryway or living room.
Date Issued 12-05-02 Interpretation 02-050
Topic: Door Width in Group R, Division 2 Occupancies
Code Section(s): Section 1003.3.1.3, California Building Code (1998 ed)
Requested by: Ralph Crane, Fire Marshal, Rancho Cucamonga Fire Protection District
P.O. Box 807, Rancho Cucamonga,CA.91729-0807
Is it the intent of Section 1003.3.1.3 to require that the net unobstructed door width, WITH NO EXCEPTIONS, be no less than 32” through bedroom doors on an existing Group R, Division 3 occupancy being converted for use as a Group R, Division 2.2.1 facility?
No. Section 1003.3.1.3 is specific to occupancies serving 10 or more clients. An existing
Group R, Division 3 being converted to a Group R, Division 2.2.1 does not fall into this
criteria and can have exit doors with a clear exit width of 28 inches as the clients will all
be ambulatory.
Date Issued 12-05-02 Interpretation 02-056
Topic: R-2 Occupancies
Code Section(s): Section 506 (#6), California Building Code (1998 ed)
Requested by: Pedro Garcia/Steve Kuchenski, 310 North Lake Avenue #920, Pasadena, CA 91101-4129
Does Provision #6 in Section 506 refer to Section 904.2.9 or does it refer to Group R, Division 2 occupancies referenced in Section 904.2.10?
Provision #6 refers to Group R, Division 2 occupancies. Provision #6 is a misprint and
should refer to Section 904.2.10 as this section is where the sprinkler requirements for
Group R, Division 2 occupancies reside.
Date Issued 12-05-02 Interpretation 02-057
Topic: Exiting in RCFE’s
Code Section(s): §1007.6, California Building Code (1998 ed)
Requested by: Aleyda and Jeffrey Hanson, Elder Eden, 1226 Bella Oaks Lane
Napa, CA 94558
Are Residential Care Facilities for the Elderly (RCFE) which have six or fewer
residents limited to direct exiting from each resident sleeping room?
No. RCFEs that house six or fewer ambulatory residents may have the type of exiting
allowed for Group R, Division 3 occupancies (single family dwellings.) RCFE’s that
house six or fewer non-ambulatory residents may have any of the following types of
exiting from each sleeping room:
a. Direct exit to exterior from bedroom.
b. Egress through an adjoining bedroom that has a direct exit to exterior.
c. Egress through hallway/corridor that has an exterior exit
d. Egress through a hallway/corridor or area and into a bedroom that has a
direct exit to exterior.
Date Issued 12-05-02 Interpretation 02-058
Topic: Group R, Division 2.1.1 Facilities
Code Section(s): Sections 310.9 & 310.10.2, California Building Code (1998 ed)
Requested by: Stephen Hart, NASIP, 1050 Eileen Way, Sacramento, CA 95831-5812
1. Is an existing (April 1991) Residential Care Facility (R-2.1.1) that has had no
change to either their license or to the building structure required to have smoke
detectors in the bedrooms?
No. There were no smoke detector requirements in sleeping rooms at the time this facility was licensed.
2. Is at least one manual pull station also required?
No. There were no pull station requirements for facilities housing six or less at the time
this facility was licensed.
Date Issued 02-10-03 Interpretation 03-002
Topic: Area of Rescue Assistance
Code Section(s): §1114B.2.1, California Building Code (1998 ed)
Requested by: Sid Akhzar, 5567 Reseda Blvd #209, Tarzana, CA 91358
Both Section 1114B of the 1998 California Building Code and ADAAG 4.1.3(g) agree that a “supervised automatic sprinkler system” overrides the requirement for Area of Rescue Assistance. Does the State Fire Marshal agree that any occupancy can dispense with rescue assistance by installing a supervised automatic sprinkler system?
Yes. Exception #1 of Section 1114B.2.1 states that areas of evacuation assistance are not required in buildings or facilities having a supervised automatic sprinkler system.
Date Issued 02-10-03 Interpretation 03-005
Topic: Residential Care Occupancies.
Code Section(s): §310.1, California Building Code (2001 ed)
Requested by: Michelle Douglas, Colton Fire Department, 303 “E” St, Colton, CA 92324
Is a small family home having a licensed capacity of four infants as defined in
Section 310 classified as a Group R, Division 2.2 occupancy?
No. The total capacity of the facility you describe is less than six clients. Since infants
can not be defined as non-ambulatory due to age per Section 210, the facility more closely resembles a Group R, Division 2.2.1 occupancy.
Date Issued: 03-25-04 REVISED Interpretation 03-018
Topic: Group R, Divisions 2.1.1 and 2.2.1
Code Section(s): §1267.8,13143,13195,13113.7(2) and 1275 California Health and Safety Code
Requested by: K Chin, Altos Care, Inc.2492 Aram Ave. San Jose, CA 95128
1. Considering the provisions of Section 1267.8(a) of the California Health and Safety Code, are commercial or residential standards for fire and life safety, egress and accessibility applicable to Group R, Division 2.1.1 occupancies when the code is interpreted by local plan checkers and fire inspectors?
Only those regulations that have been adopted by the State Fire Marshal shall apply to fire and life safety, egress and accessibility.
2. Should local fire inspectors or planners cite commercial or residential standards when inspecting a Group R, Division 2.1.1 occupancy?
No. Commercial standards do not apply to Group R, Division 2 occupancies. The Health and Safety Code requires that these facilities model as closely as possible to a Group R, Division 3 Occupancy.
3. Considering the provisions of Section 1267.8 of the Health and Safety Code, what are the closest occupancy standards for life safety, egress and accessibility that “special occupancy” fire department planners and inspectors should be using when inspecting a Group R, Division 2.1.1 occupancy (i,e. can local fire departments apply commercial standards)?